On Friday, Judge Matthew J. Maddox of the U.S. District Court for the District of Maryland ruled that the removal of Democratic Commissioners from the Consumer Product Safety Commission (“CPSC”) without cause was unlawful. This decision arises from a lawsuit filed by Commissioners Mary Boyle, Alexander Hoehn-Saric, and Richard Trumka Jr. against President Donald J. Trump, Secretary of Treasury Scott Bessent, Director of the Office of Management and Budget Russell Vought, and Acting Chairman of the Commissioner Peter A. Feldman.
The Commissioners argued their removal violated statutory “for-cause” protections, which only allow removal for neglect of duty or malfeasance in office. The court granted their motion for summary judgment, awarded injunctive relief, and ordered their reinstatement through a writ of mandamus.
Temporary Restraining Order and Preliminary Injunction
This final decision follows Judge Maddox’s earlier denial of the Plaintiffs’ request for a temporary restraining order and a preliminary injunction, citing concerns about potential disruption if the Commissioners were reinstated and removed again during litigation. The court referenced the Supreme Court’s guidance in Trump v. Wilcox1 to avoid instability. Now, with a final judgment, those concerns are moot.
Key Summary Judgment Arguments
On May 30, 2025, Plaintiffs sought summary judgment, relying on the Supreme Court’s decision in Humphrey’s Executor v. United States2. This landmark decision affirmed Congress’s authority to limit the President’s power to remove members of independent agencies.
In response, on June 4, 2025, Defendants filed a cross-motion for summary judgment, arguing that such statutory protections unconstitutionally restrict the President’s Article II authority to oversee executive officers. According to Seila Law LLC v. Consumer Financial Protection Bureau3, Defendants claimed that Commissioners, as principal offices, should be removable at the President’s discretion.
Defendants further contended that, even if the removal protections were upheld, the court lacked the authority to reinstate the Commissioners, warning that such an order would raise separation of powers concerns. They also argued that any harm to Plaintiffs could be addressed through backpay, not reinstatement, and that the court’s equitable powers did not extend to ordering their return.
The Final Opinion
The court held that CPSC’s statutory tenure arguments are constitutionally justified under Humphrey’s Executor exception, which allows for-cause removal protections for certain independent agencies. The court determined that the statutory restriction on removing CPSC Commissioners does not infringe upon the President’s Article II removal power, noting that the CPSC’s multimember, bipartisan structure with staggered terms aligns with the characteristics that justify such protections.
The court also found that the wrongful removal of independent agency commissioners is an extraordinary circumstance that disrupts official duties and warrants judicial intervention. The court concluded that each Plaintiff has a clear and indisputable right to their office and that Defendants must reinstate them and provide the necessary resources to perform their roles.
This decision not only reinstates the three democratic Commissioners but also reinforces the importance of statutory protections for independent agency officials. By upholding these safeguards, the court affirmed the critical role of independent regulatory bodies in protecting the public interest from undue political interference.
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